Alaska Department of Environmental Conservation Division of Water

Ted Stevens Anchorage General Permit (ANC-GP) FAQs

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Transition from MSGP to ANC-GP

1. Do I need coverage under the Multi-Sector General Permit (MSGP) and the Ted Stevens Anchorage General Permit (ANC-GP)? Can I choose which permit my facility is covered by?

This permit action is carried out under Section 2.8.1 of the MSGP – DEC may require a permittee to apply for and obtain authorization to discharge under an alternative permit. You need to be covered by only one permit. A facility cannot choose which permit it is covered by. All MSGP covered facilities on the airport property will have to be permitted by the ANC-GP.

2. What activities/facilities are covered by the ANC-GP?

Operators of industrial facilities at Ted Stevens Anchorage International Airport (ANC) that require a Stormwater permit are required to obtain coverage under the ANC-GP if their activities are included within one of four Standard Industrial Classification (SIC) Codes:

• 4512 – Air Transportation, Scheduled
• 4513 - Air Courier Services
• 4522 - Air Transportation, Nonscheduled
• 4581 - Airports, Flying Fields, and Airport Terminal Services

3. Why develop another permit for the Airport?

This permitting effort is the result of tracking water quality results for the MSGP benchmark exceedances for the past six years at the airport. On January 24, 2014 DEC requested ANC to conduct sampling to see if the change in runway deicing agent would reduce the number of exceedances of the MSGP Sector S Benchmark for Biological Oxygen Demand (BOD) and Chemical Oxygen Demand (COD). From the data provided on November 9, 2015 it appears that ANC still consistently exceeds the BOD and COD benchmarks. ANC has exceeded the residue water quality standard at least three times since 2009.

4. How is the ANC-GP different from the MSGP for a co-permittee?

The new items for a co-permittee includes:

1. For those who apply more than 30,000 gallons of glycol annually, measured as undiluted product, they have to apply source reduction techniques listed in the permit (ANC-GP Part 4.2.2.8.2).
2. They have to participate in the evaluation of the feasibility of recycling spent aircraft deicing fluid for reuse as aircraft deicing fluid at the airport (ANC-GP Part 6.2.1.9).
3. They have to participate in the development and implementation of the Adaptive Management Plan (ANC-GP Part 6.0). MSGP items they no longer have to do includes: conducting quarterly visually monitoring.

5. How is the ANC-GP different from the MSGP for the Airport Authority?

The new items for the Airport Authority includes:

1. Conduct discharge monitoring at five outfalls from the facility (ANC-GP Part 3.2).
2. Conduct Whole Effluent Toxicity testing from Outfall B and D (ANC-GP Part 3.5)
3. Conduct Lakes Hood and Spenard monitoring (ANC-GP Part 3.6)
4. Participate in the evaluation of the feasibility of recycling spent aircraft deicing fluid for reuse as aircraft deicing fluid at the airport (ANC-GP Part 6.2.1.9).
5. Address residue violations of water quality standards (ANC-GP Part 9.3)
6. Participate in the development and implementation of the Adaptive Management Plan (ANC-GP Part 6.0).

6. How is the ANC-GP going to reduce discharge of deicing fluid into the receiving waterbodies?

The permit requires source reduction techniques in the application of deicing fluid onto aircraft, within the bounds of FAA aircraft safety considerations. It is anticipated the glycol usage reduction techniques of; forced air, proportional mix nozzles, or low flow nozzles, will reduce the amount of glycol being applied to the aircraft. The permit also requires a study for the capture and recycle of aircraft deicing fluid.

Permit Mechanics

7. How do I pay for permit fee and when is it due?

It can be paid by check payable to “State of Alaska” or by credit card. The permit fee is $735 per year starting in January, 2020. Note, include a copy of your NOI with your payment to ensure that your payment is credited to your permit authorization. After the first year, DEC will invoice you annually for the permit fee.

8. Who is responsible for conducting monitoring of the outfalls?

The Airport Authority is responsible for collecting, testing, and reporting the results of discharge from each of the outfalls. The Airport Authority is responsible for the quarterly visual monitoring. The Airport Authority is responsible for conducting Lakes Hood and Spenard receiving water monitoring. The co-permittees are not responsible for any water quality monitoring.

9. Who is required to get permit authorization?

Air transportation activities commonly occur on land not owned by the co-permittee conducting the activities. If a co-permittee does not own or lease land at the airport, but is still conducting activities which would require industrial stormwater permit coverage, the co-permittee must apply for industrial stormwater permit. If smaller airline conglomerates are under common ownership, and the parent company agrees, the smaller airline can be an operator under the larger entity’s permit application. At the airport, all tenants regulated by the ANC-GP are required to obtain separate industrial stormwater permit coverage. “Tenant” means airline carriers, air cargo, fixed-base operators (e.g. fueling companies, deicing companies, and maintenance shops), and others that have leases/agreements with the airport authority to conduct business on airport property. Tenants of the airport that conduct industrial activities as described in ANC-GP Part 1.2.1, or as described anywhere in 40 CFR 122.26(b)(14), are required to apply for authorization.